Privacy Policy

At Dune Real Estate Partners LP, we are committed to protecting
and respecting your privacy. This policy explains how we collect
and use any personal information (i.e., any information that
relates to you and that identifies or can be used to identify you)
that you share with us, including how we collect, process, protect
and share your personal information.

You do not need to take any action as a result of this privacy
policy, but you may have certain rights as described below. We keep
this privacy policy under regular review and will advise you of any
updates or changes to this privacy policy. This privacy policy was
last updated in May 2018.

When you provide us with your personal information, Dune Real
Estate Partners LP and its affiliated entities (including, without
limitation, any investment funds or vehicles) (collectively,
"Dune", "we", "us" and "our") may act as a "data controller". In
simple terms, this means that we: (i) "control" the personal
information that you provide, including making sure that it is kept
secure; and (ii) make certain decisions on how to use and protect
your personal information, but only to the extent that we have
informed you about the use or are otherwise permitted by law.

If you have any questions regarding our use of your personal
information, or this privacy policy, please contact
info@drep.com.

The types of personal information we collect about you depends
on the product or service you have requested from us and/or the
nature of your interaction with us. The types of personal
information we collect includes contact information (such as name,
postal and email address and telephone number) and other personal
information you submit to us, such as the information you provide
to us when you correspond with us in relation to inquiries.

The personal information collected about you will help us
provide you with a better service and facilitate our business
relationship.

We do not knowingly collect or solicit personal information from
anyone under the age of 16.

How we obtain your personal information

We collect information about you directly when you provide it to
us in online correspondence and in conversations (including via
email and telephone).

In an offline context, we also collect information about you
from the forms and any associated documentation that you complete
when subscribing for an investment and/or establishing a
relationship with us, including KYC and anti-money laundering
information. This will include information about your name,
address, date of birth, passport details or other national
identifier, driving licence, and your national insurance or social
security number and/or taxpayer ID.

We also collect personal information about you from third
parties during our investment process, both during diligence on
entities that we are considering purchasing or investing in and
after making such investments, in each case from such potential or
actual investment entities, as part of our continuing interest in
such investments and compliance with legal obligations in relation
to such investments.

We will only collect and process personal information about you
where we have lawful bases to do so (please see section 3
below).

We may combine personal information that you provide to us with
information that we collect from, or about you from publicly
available sources. This will include information collected in an
online or offline context.

Why we use your personal information

We will use the personal information you provide us with for the
following purposes, and pursuant to the corresponding legal bases,
among others:

Purpose

Legal Basis

To enter into, and perform, contracts with you that you have
requested.

Contractual necessity

To improve our website and the products and services that we
offer and notify you about changes to our services.

Legitimate interest

To respond to requests for information submitted by you through
our website.

Legitimate interest

To keep a record of your relationship with us.

Legitimate interest and legal obligation

To monitor our investments and comply with our legal
obligations in relation to them.

Legitimate interest and legal obligation

Additionally, we will use your personal information to keep you
informed of our products and services (e.g. future funds that we
are raising), if you have provided your consent to us doing so, or
based on our legitimate interest where we have an existing
relationship with you and we wish to contact you about products and
services similar to those which we provide you, in which you may be
interested. You may opt-in to certain kinds of marketing, or all
forms of marketing at any time, by contacting us and you may
unsubscribe to receiving emails by clicking on the "opt-out" link
provided in all our marketing emails.

No automated decision making, including profiling, is used when
processing your personal information.

If we require your personal information due to a legal
requirement or obligation, or in order to perform a contract with
you, we will make you aware of this at the time we collect your
personal information and the possible consequences of you failing
to provide this personal information (unless we are restricted from
doing so under applicable law).

Who we share your personal information with

We will share your personal information with third parties as
required by law or regulation.

We will also share your personal information with affiliates and
certain service providers and professional advisors, including: (i)
fund managers, depositories, administrators, custodians and
investment advisors; (ii) service providers; and (iii) our lawyers,
auditors and other professional advisors, in order to provide
services on our behalf, as necessary to fulfil the purposes set out
in this privacy policy.

We make sure any third party that provides a service to or for
us generally covenants within a defined standard to:

(i) enters into an agreement with us and meets our standards for
data security;
(ii) not to use your personal information for any purpose other
than the clearly defined purpose relating to the service that such
party is providing;
(iii) not to share your personal information with any organization
without our consent (apart from us); and
(iv) hold your personal information securely and retain it only
for such period of time as we instruct.

We will also share your personal information with applicable
third parties in the event of a reorganization, merger, sale,
acquisition, assignment or other disposition of all or a portion of
our business, assets or shares.

How we keep your personal information secure

We are committed to protecting the personal information you
entrust to us, and to that end we employ appropriate
organizational, physical, technical and procedural safeguards to
protect your personal information in our possession or under our
control to the extent possible from unauthorized access and
improper use.

We also train and instruct our employees that all personal
information must be handled in accordance with this privacy policy
and applicable privacy and data protection laws, and any misuse by
employees is subject to disciplinary action.

Our retention of your personal information

We will keep your personal information only for as long as is
necessary for the purposes it was collected for, set out in section
3 of this privacy policy, unless a longer retention period is
required under applicable law. To determine the appropriate
retention period for personal information, we consider the amount,
nature, and sensitivity of the personal data, the potential risk of
harm from unauthorised use or disclosure of your personal
information, the purposes for which we process your personal
information and whether we can achieve those purposes through other
means, and the applicable legal requirements.

For further information regarding how long we will keep your
personal information, please contact us using the details outlined
in section 10 of this privacy policy.

Transfers of your personal information

To the extent that you reside in the European Union, or EU data
privacy legislation applies to you, and we transfer your personal
information to countries located outside of the European Economic
Area ("EEA"), such transfers are made in compliance with applicable
data privacy laws. Please contact us for information in relation to
the particular safeguards or derogations used in any particular
circumstance.

Your rights

To the extent that you reside in the European Union, or EU data
privacy legislation applies to you, you have the right to access
the personal information we hold about you, and there are a number
of ways you can control the way in which and what information we
store and process about you. We have explained these individual
rights and controls below. To exercise these rights and controls,
please contact us at info@drep.com.

Access: You have the
right to ask for details of the personal information that Dune
holds about you free of charge, however we may charge a 'reasonable
fee' if we think that your request is excessive, to help us cover
the costs of locating the information you have requested. We will
respond to your request as soon as possible and (save for in
certain circumstances) within one month.

Correction: If there
are any inaccuracies in the information we hold about you, please
contact us and we will correct them.

Deletion: If you
think that we shouldn't be holding or processing your personal
information any more, you may request that we delete it. Please
note that this may not always be possible due to legal
obligations.

Restrictions on
use: You may request that we stop processing your
personal information (other than storing it), if: (i) you contest
the accuracy of it (unless the accuracy is verified); (ii) you
believe the processing is against the law; (iii) you believe that
we no longer need your personal information for the purposes for
which it was collected, but you still need your data to establish
or defend a legal claim; or (iv) you object to the processing and
we are verifying whether our legitimate grounds to process your
personal information, override your own rights.

Object: You have the
right to object to processing, including: (i) for direct marketing;
(ii) for research or statistical purposes; and/or (iii) where
processing is based on legitimate interests.

Portability: If you
wish to transfer your personal information to another organization
(and certain conditions are satisfied), you may ask us to do so,
and we will send it directly if we have the technical means.

Withdrawal of
consent: If you previously gave us your consent
to allow us to process your personal information for a particular
purpose, but you no longer wish to consent to us doing so, you can
contact us to let us know that you withdraw that consent. If you do
not do so, we may continue to rely upon that previous consent to
keep using and processing your personal information in the same
way.

This website may contain links to other websites. Dune is not
responsible for the privacy practices or the content of such third
party websites. Please see our online Terms of Use for more information about
our online terms and policies.

Cookies

This website does not use cookies (our cookies or third party
cookies) and so we do not collect any type of information about you
in this manner. If you would like to learn more about cookies in
general and how to manage them, visit aboutcookies.org or www.allaboutcookies.org.

Supplemental notice to California Residents

If you are a resident of California, applicable law permits you
to request information regarding the disclosure of any personal
information collected by us about you to a third party for third
party marketing purposes. To make such a request, please contact us
at info@drep.com or write us at: Dune Real Estate Partners LP, 640
Fifth Avenue, 17th Floor, NY, NY 10019.

Contact us

For any questions regarding our processing of your personal
information (including the rights and controls explained in section
8 of this privacy policy) please contact info@drep.com.

Complaints

If you reside in the European Union, or EU data privacy
legislation applies to you, and you should you wish to lodge a
complaint with regards to how your personal information has been
processed by Dune, please contact your local supervisory authority.
In the UK, this is the Information Commissioner https://ico.org.uk/concerns.